Copies of evidence and correspondence for Nicholas Brown, MP

I can confirm that we hold information relevant to your request.

Please find attached to this email copies of the documents. Some information has been redacted from the documents and is subject to a Refusal Notice under sections 31, 38 and 40 of the FOIA and in accordance with Section C of IPSA’s Publication Policy.

Section 31(1)(a) – law enforcement

This exemption applies where the disclosure of information would or would be likely to prejudice the prevention of crime.

IPSA relies on this exemption to withhold the banking details of IPSA and other transactional references. IPSA believes that the disclosure of these details could leave those concerned more vulnerable financial crime, in particular fraud and electronic crime, especially with the increase in cyber attacks.

This exemption is subject to a public interest test. IPSA does not consider the withholding of this information has a negative impact on the understanding of these claims. We therefore find that the public interest in withholding this information outweighs the public interest in disclosure at this time.

Section 38(1)(b) – health and safety

This exemption applies where the disclosure of information would or would be likely to endanger the health and safety of any individual.

IPSA relies on this exemption to withhold the address of the MP’s constituency offices which are not in the public domain because they are occupied by other tenants. Section 38 is a qualified exemption and is therefore subject to a public interest test.

Following the attack on Westminster Bridge in London, the IPSA Board agreed that it would no longer publish any details regarding MPs’ travel arrangements which could potentially put at risk the safety of MPs and their families. IPSA believes that MPs’ safety is still at risk and therefore maintains that the public interest in withholding this information outweighs the public interest in disclosure.

Sections 40(2) and 40(3A)(a) – personal data

This exemption applies to information which IPSA considers to be personal data within the meaning of Article 4(1) of the UK General Data Protection Regulation 2016 (UK GDPR) which states:,

"personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly.

IPSA considered that the following are personal data within this definition:

• name of the supplier

• name of the landlord

• name of IPSA staff

We then considered whether disclosure of this personal data would breach any of the Principles relating to the processing of personal data in the UK GDPR.

The relevant principle falls at Article 5(1)(a):

Personal data shall be:

a. Processed lawfully, fairly and in a transparent manner in relation to the data subject.

As IPSA was unable to find a lawful basis on which it could rely, within Article 6 of the UK GDPR, it therefore finds that the information is exempt under section 40.